Does Tribunal have power to grant stay beyond period of 365 days prescribed in Act?

Reliance in this regard can be placed on the decision of Hon’ble Delhi High Court in case of Pepsi Foods Private Limited vs. ACIT [W.P.(C) 1334/2015] pronounced on 19-05-2015 wherein the petitioner has challenged the constitutional validity of Section 254(2A) of the Income Tax Act, 1961 (here-in-after referred to as ‘the Act’). The said section provides that Tribunal cannot extend the period of stay for a period exceeding 365 days from the initial grant of stay even if the delay in disposing off the appeal is not attributable to the assessee. The petitioner pleaded that the said provisio...